Bill of Complaint of Martha TURNER (1836): Charles County, Maryland Transcribed and contributed by Herman Stephan Copyright 2004. All Rights Reserved. http://www.usgwarchives.net/copyright.htm http://www.usgwarchives.net/md/mdfiles.htm ******************************************************************************** BILL OF COMPLAINT OF MARTHA TURNER To the Honorable Theodorick Bland Chancellor of Maryland The Bill of complaint of MARTHA TURNER humbly shows, that she is the widow of THOMAS TURNER late of Charles County in the State of Maryland who departed this life on or about the Eighth day of April in the year Eighteen Hundred and THIRTY Six (1836) , seized and possessed of the following tracts a part, of tracts of land lying and being in Charles County aforesaid, to wit a lot or parcel of ground with the improvements therein, in New Port in the County aforesaid which was conveyed to her said husband THOMAS TURNER, in the year Eighteen hundred and Fifteen, being part of a tract or parcel of land called "SAINT THOMAS" a ------- reference to said conveyance will appear - and also of one other tract a part of the tract of land lying in the county, aforesaid, which was conveyed to the said husband, by EDWARD B. MORAN, in about the month of October in the year Eighteen Hundred and Twenty eight as -----reference to the deed therefore will appear, the said tract, being a part of " Keys Addition" and containing sixty six and one half acres more or less and of the other -----parcels of land which were conveyed to her said husband by SAMUEL S. BRISCOE, WILLIAM HENDLY SMOOT, ----- and PHILIP KING -----deed bearing date on or about the Twentieth Day of March in the year Eighteen Hundred and Twenty (1820) of ---reference ------appears, -----"Partnership", "TURNERS CHANCE", "CHUMMS ADDITION", Part of "WILTON", and "EAST MARLING" containing in the whole about three hundred and fifty one acres, and all lying in Charles County aforesaid - and --- -, charges that her said husband THOMAS TURNER in his life time ------on or about the Sixth day of May in the year Eighteen Hundred and Twenty, (6 MAY 1820) purchased ---------AQUILA TURNER, two tracts or parcels of land lying in the county aforesaid called "MOUNT PLEASANT", and part of "WATERS CHANCE" containing together one hundred and sixty one acres more or less - the ? purchase convey ----- said parcels of land being eight Hundred --------- was paid exclusively by the said husband, ---------believes and -------- things, for the purpose of depriving her of her right to Dower therein, her said husband ????? the conveyance after said parcels of land to be made ----------said AQUILA TURNER, to himself and said THOMAS TURNER for life to ?????son JOHN M. TURNER after his death - and she further charges that on or about the Twenty Eighth Day of June in the year Eighteen Hundred and Thirty her said husband the said THOMAS TURNER purchased of BENEDICT EDELEN one ---- lot a parcel of ground, being part of a tract called " ST. THOMAS" near the Village of New Port in the County aforesaid containing ten acres more or less. -------The purchase ---- ----- ----parcel of land was also paid exclusively --- her said husband, but that in order to deprive her of her dower right therein also, her said husband caused the conveyance therefor -made to himself for life, and after his death to his daughter SUSANNA E. TURNER in full. And the? Archaic, charges entire purchase ----of the parcels of land was paid by her said husband, and that the object and only object of leaving the conveyances made in the --- before, continued, was to deprive the *Archaic, of the dower right therein., but Archaic is advised and therefore charges, that in as much as the -----consideration future parcels of land was paid by her said husband, the entire use resulted to him, and that she after his death became entitled to Dower therein. And the *Archaic? (Consort) further charges that her said husband on or about the first day of July in the year Eighteen Hundred and Thirty (1831) , conveyed to one JAMES T. THOMAS of Charles County further pretended consideration ------there ------ ------ and which of the aforesaid parcels of land, together with all his personal estate, as afore reference to an authenticated copy of said deed worked ---- ------ ------ she -----be taken a part of this bill -- appear. And she charges that the consideration continued in said deed or any part thereof and was paid by the said JAMES P. TURNER the grantee, and that the same is fraudulent and ----, and --- ----- taken right to Dower in said lands, she never having relinquished her said right. --- ---said JAMES P. TURNER, on or about the fifth day of July (5th of July) in the year past aforesaid, conveyed all the said real and personal property as aforesaid conveyed to him by the said THOMAS TURNER, to certain EDWARD TURNER and AQUILA TURNER of Charles County aforesaid, further pretended consideration of Five Thousand Dollars, (in part publish ----consort(*Antric) a wife and never paid) upon certain trusts as will therein appear. And the *Antric files herewith a copy of said and marked exhibit --- and ----the same way be taken and considered as a part of this bill. And she further states, that her husband the said THOMAS TURNER departed this life as before stated on about the Eighth day of April in the year Eighteen Hundred and Twenty Six (1826) leaving the --- -----children his heirs at law, to wit, SUSAN E. Of full age, the wife of JOHN M. LATIMER, of Charles County, JOHN R. TURNER also of full age, and THOMAS PHILIP TURNER and FRANKLIN PARNHAM TURNER minors to the age of twenty one years. And *Antrics charges that her said husband continued and remained to the period of his death as -----,-----seized and possessed of the aforesaid land and real estate, and died so seized and possessed and that therefore his aforesaid ---taken possession thereof, and have continued so in possession from that time to the present. Receiving the rent and profits thereof and the *Antric is advised that she is entitled to one third of the said lands and premises during her life and to one third of the rents and profits thereof from the day of his death offer said husband until her Dower shall be assigned --, as by law she is entitled and she charges that the ans applied to the said ----at law and grantees to assign----in ----the said premises, and to pay one third of the rents and profits thereof further time her right accrued as aforesaid, ----- ---- ---- -----. ---- ---- therefore that the said JOHN M. LATIMER and SUSANNA E. His wife, JOHN R. TURNER, THOMAS PHILIP TURNER, FRANKLIN PARNHAM TURNER, JAMES P. TURNER, EDWARD TURNER and AGUILA TURNER, all of Charles County aforesaid, may answer the several matters and things herein before started, and that they and lack of them may --- of intent part, and of the said lands ------- and premises ---, and lack of them are in possession ---the ----- ------since the death of the said THOMAS TURNER, and that the said parties may be decreed to assign to the *Antric, one third of the rents and profits of the same further time of the death of the aforesaid husband the said THOMAS TURNER , and --- ---- Antric may ---- such ----- and further relief as here case may require. May it please --- ---- ---- to grant unto the Antric -- --- of Supeana against the said JOHN M. LATIMER and SUSANNA E. LATIMER his wife, JOHN R. TURNER, THOMAS PHILIP TURNER, FRANKLIN PARMHAM TURNER, JAMES T. THOMAS, EDWARD TURNER and AQUILA TURNER R all of Charles County commanding them to appear in this court, at same certain day --- therein -------to answer the promises and abide by and inform such decree, as may be posses therein and the Antic will pray - (unable to make out Court Clerks names) (This is the one labeled MARTHA TURNER @ JOHN M. LATIMER AND OTHERS. In Chancery To the Honorable Theodorick Bland Chancellor of Maryland The petition of the complainant respectfully states that the answers being filed, and the cause at issue, she now prays your Honor to direct a Commission to issue to take proof there being no slandering commissioners in the County where the Witnesses reside, the names as Commissioners, Waller H. Mitchell, John Matthew, Wm B. Stone, George Brent of Charles County and they will pray. In Chancery 31 July 1845 Ordered that a commission issue as prayed by the foregoing application to the persons therein named unless the Defendants name and ------ Commissioners on or before the Tenth day of September next, -----that a copy of this order together with a copy of the ----- ----served on the defendants their Solicitors on or before the Twentieth day of August Next Theodorick Bland clerk. Copy of Service filed 15 April 1845 Test: LOUIS GASSAWAY * ARCHAIC----- Surviving from a earlier period, antiquated